PTAB

IPR2016-00679

ASSA ABLOY Ab v. UniKey Technologies Inc

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Wireless Access Control System and Related Methods
  • Brief Description: The ’210 patent describes wireless access control systems, particularly passive keyless entry (PKE) systems for door locks. The technology allows a user to operate a lock using a remote user access device without needing a traditional key, with features triggered by user proximity and acceleration of the remote device.

3. Grounds for Unpatentability

Ground 1: Obviousness over Howarter and Willats - Claims 1, 3, 4, 6, 7, 9, 10, 12-15, 17, 18, and 20 are obvious over Howarter in view of Willats.

  • Prior Art Relied Upon: Howarter (Application # 2010/0075656) and Willats (Application # 2003/0008675).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Howarter, which was not considered during prosecution, discloses the core elements of the challenged claims. Howarter teaches a vehicle access system where a cell phone (user access device) communicates with a vehicle's lock assembly. It discloses using signal strength for proximity detection, an accelerometer within the phone to detect tactile input (e.g., a double tap) to generate an unlock command, and a lock controller to actuate the locks. Petitioner contended this maps to the primary limitations of independent claim 1. However, Petitioner argued Howarter’s system communicates at a constant rate. Willats was introduced to remedy this, as it teaches a PKE system that conserves battery power by operating at a low-rate periodic scan mode until a user device is detected, at which point it switches to a higher-rate interrogation mode to eliminate user-perceived delay.
    • Motivation to Combine: A POSITA would combine Howarter with Willats to improve battery life, a well-known design concern in wireless access control systems. Howarter’s system runs on battery power, and incorporating Willats’s variable polling rate functionality would provide the predictable benefit of power conservation without negatively impacting user experience—a routine upgrade to a known system.
    • Expectation of Success: The combination involved applying a known power-saving technique (variable polling rate from Willats) to a known type of system (wireless access control from Howarter) to achieve a predictable result (extended battery life), leading to a high expectation of success.

Ground 2: Obviousness over Howarter, Willats, and Hassan - Claim 2 is obvious over Howarter in view of Willats and Hassan.

  • Prior Art Relied Upon: Howarter (Application # 2010/0075656), Willats (Application # 2003/0008675), and Hassan (Application # 2010/0171642).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground builds upon the combined teachings of Howarter and Willats from Ground 1. Claim 2 depends from claim 1 and specifies that the user access device is a "key fob." While Howarter primarily discloses a cell phone, it mentions other electronic devices. Hassan explicitly discloses a PKE system using a key fob that includes an accelerometer for controlling vehicle functions.
    • Motivation to Combine: A POSITA would have found it obvious to substitute the cell phone in the Howarter-Willats system with the key fob taught by Hassan. This was argued to be a simple substitution of one known element (a portable wireless device) for another to obtain predictable results, as key fobs and cell phones were well-known alternative user devices for PKE systems.
    • Expectation of Success: The substitution was a predictable design choice with no technical hurdles, as both devices perform the same function in analogous systems.

Ground 3: Obviousness over Howarter, Willats, and McLintock - Claims 21 and 22 are obvious over Howarter in view of Willats and McLintock.

  • Prior Art Relied Upon: Howarter (Application # 2010/0075656), Willats (Application # 2003/0008675), and McLintock (Application # 2002/0099945).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground addresses dependent claims 21 and 22, which add limitations requiring a clock and memory for storing operational time periods to grant access only at specific, authorized times. Petitioner argued that while Howarter discloses a multi-user system with customizable preferences, it lacks explicit time-based access controls. McLintock was introduced because it teaches a multi-user door access system (for residential, commercial, and automotive use) that uses a clock and memory to grant access privileges that are "variable according to time."
    • Motivation to Combine: A POSITA would have been motivated to add McLintock’s time-based authorization to the Howarter-Willats system to enhance security and convenience, particularly in a multi-user context. This functionality would be a logical and desirable upgrade for managing access for different users (e.g., family members, service personnel) at different times, a known need in access control systems.
    • Expectation of Success: Implementing time-based rules is a known software/firmware function in access control. Integrating this feature from McLintock into the controller of the Howarter system would have been a straightforward task for a POSITA with a reasonable expectation of success.

  • Additional Grounds: Petitioner asserted additional obviousness challenges based on other combinations, including Howarter with Luebke (for light/audio proximity sensors), Popelard (for touch-pattern recognition), and various permutations of these references to address the remaining dependent claims.

4. Key Claim Construction Positions

  • Petitioner argued for a construction of the term "communication rate," which is not explicitly defined in the ’210 patent’s specification.
    • Based on specification language describing a "low frequency rate" to conserve power and a "faster rate" to eliminate delay, Petitioner proposed that a POSITA would interpret "communication rate" to include selectively increasing or decreasing the rate or frequency of communication events (e.g., transmissions or listening events). This construction was critical to mapping prior art like Willats, which teaches switching from a slow "periodic scan" to a faster "interrogation mode," to the claim language.